HBMA Invited to Testify Before NCVHS

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07/20/2012

Solutions
discussed when converting from ICD-9 to ICD-10

LAGUNA
BEACH, Calif. – July 10, 2012 -- The Healthcare Billing & Management
Association (HBMA) is keenly aware of the difficulties involved in making the
conversion from ICD-9 to ICD-10 CM. This is why HBMA,the premiere non-profit educational
resource and advocacy group representing third-party medical billing companies
and billing professionals, was invited to Washington to testify before The
National Committee on Vital and Health Statistics (NCVHS), Standards
Subcommittee.

NCVHS is the National Committee
charged with advising the Secretary of Health and Human Services on all HIPAA
related matters.

HBMA
is concerned that unless the
“lessons learned” from 5010 materially inform and affect the implementation of
ICD-10 CM, the economic stability of America’s healthcare reimbursement systems
will be at risk and could be severely compromised, affecting provider financial
viability and patients’ access to care, a concern we know CMS acknowledges.

Holly
Louie, CHBME, Chair of the HBMA ICD-10/5010 Committee presented the association’s
views on “lessons learned” from the 5010 implementation and how those lessons
can and should be applied to avoid problems with ICD-10 implementation.

In
Louie’s testimony, she said, “HBMA believes that we MUST learn from the
mistakes that were made in transitioning
from 4010 to 5010, and undertake the transition from ICD-9 CM to ICD-10 CM in a
way that demonstrates we learned those lessons.”

“If all we
accomplish as a result of this notice of proposed rulemaking (NPRM) is moving
the date from October 1, 2013 to October 1, 2014 or some later date, then we
will have failed to make the changes that will be necessary to ensure that the
new date is final and the transition is successful. More importantly, we
will merely be delaying the likelihood for payment disruptions and patient
access to care problems from 2013 to 2014.”

In
the view of HBMA, central among the shortcomings in the 5010 transition was the
lack of a standard definition of what it meant to be “5010 ready.”

HBMA
strongly recommends that the following be adopted in conjunction with the delay:

CMS should adopt
and enforce a uniform definition of ICD-10 CM “ready”. “ICD-10 CM
ready” should mean, at a minimum, the complete end-to-end testing of 837 and
835 transactions in full production have successfully been accomplished.
Any maps or crosswalks used by a health plan to adjudicate a 5010/ICD-10 CM
compliant claim must be publicly available and the diagnosis code(s) used for
claims adjudication are reported.

Any entity (billing company, software
vendor, clearinghouse health plan, provider, etc.) that cannot document that
they meet this definition of ready, should be prohibited from publicly
asserting that they are ICD-10 CM “ready.” Entities improperly asserting
ICD-10 CM readiness would be subject to fines and penalties.

HBMA recommends that
health plan coverage policies be published by October 1, 2013. This would
allow adequate time for education and training, programming, data analysis and
other preparations for ICD-10 CM.

HBMA recommends
that CMS create a national bulletin board where all health plans can enter
their name, date ready for testing, date ready for production, links to any
ICD-9 CM/ICD-10 CM maps or crosswalks the plan may use during the transition
and contact information for each along with the site where any companion guides
can be located and downloaded. CMS could use this national bulletin board
as a means of tracking and publicly reporting health plan readiness.
Providers would know ahead of time which plans were on-schedule and those that
were behind. Consumers would also be able to ascertain whether their plan
was on schedule and make insurance purchasing decisions accordingly.

HBMA recommends that the new date be adopted, subject to the identification of
specific, verified readiness criteria for providers and insurers. If
these deadlines were not met by health plans due to blatant disregard for
making the necessary changes, CMS has the authority to impose penalties for
failure to be HIPAA compliant. CMS should be prepared to exercise – and
announce its intention to exercise – the penalty imposing authority for failure
to meet the various milestones.

HBMA
members process both
physician and non-physician provider claims as well as hospital claims integral
to the U.S. healthcare delivery system. A typical HBMA member processes
approximately 350,000 – 400,000 claims per year, although some companies do
much more. HBMA’s expert remarks were made on behalf of the membership with
the goal of making this transition as smooth as possible for the entire medical
community.